The Swedish Gaming Inspectorate, Spelinspektionen, has released guidelines on legal compliance and the risks of financial crime in the gaming industry. These guidelines aim to provide clarification and guidance to operators in the Swedish market. The document highlights the need for licensees to carry out risk assessments and implement risk-based internal procedures to prevent money laundering and terrorist financing. It emphasizes the importance of continuous review and updates of the risk assessment to ensure its accuracy.
Under the Money Laundering Act, licensees are required to take risk-based measures to prevent their companies from being used for illicit activities. Resources should be allocated based on the highest risk of money laundering and terrorist financing. Licensees must have internal routines and procedures in place to combat financial crime, including measures for customer awareness, monitoring, and reporting. Staff should receive appropriate training to understand licensee routines and guidelines, tailored to their roles and responsibilities.
Know-Your-Customer (KYC) standards should be implemented to verify the identity of all account holders through e-identification. Operators must collect relevant information to assess the risk associated with individual customers and identify any deviations from expected behavior. The guidelines provide thresholds for assessing the risk level, with deposits up to €2,000 during a rolling 12-month period considered low risk. Higher deposits or other AML risk indicators may categorize customers as normal or high risk. High-risk circumstances include unusual game patterns, large transactions, and reluctance to provide requested customer knowledge or documentation.
Spelinspektionen encourages licensees to ask more questions when registering new customers to better understand the origin of future deposits. To reduce the risk of money laundering and financing of terrorism, closed loop transactions can be employed, limiting withdrawals to the account from which the deposit was made.
To comply with the Money Laundering Act, licensees should collect and document customer knowledge, transaction information within commercial connections, and individual transactions subject to customer judgment requirements. Operators are obliged to review and report suspicious transactions. If suspicions persist after initial analysis, the case must be reported to the Financial Police.
In recent news, operator Mr Green, owned by William Hill, received two warnings and penalty fees totaling SEK31.5m from Spelinspektionen. The penalties were issued due to failures in responsible gambling and anti-money laundering (AML) and know your customer (KYC) responsibilities.
